4. If, pursuant to paragraph 1, a person other than the natural person resides in both States Parties, the competent authorities of the States Parties shall endeavour to determine by mutual agreement the State Party in which that person resides for the purposes of this Convention. In the absence of a reciprocal agreement between the competent authorities of the States Parties, the person shall not be considered to be resident in one of the States Parties in order to receive the benefits granted by the Convention, with the exception of the benefits provided for in articles 25, 26 and 27. That`s why we offer a free initial consultation with a qualified accountant who can provide you with answers to your questions and help you understand if a double taxation treaty might apply to you and help you save significant amounts of unnecessary taxes. All unresolved issues arising from the case are subject to arbitration at the request of the individual. However, such unresolved issues should not be the subject of arbitration proceedings if a court or administrative tribunal of either State has already ruled on such matters. To the extent that a person directly concerned by the case does not accept mutual agreement to enforce the arbitration decision, this decision is binding on both States Parties and shall be transposed into the domestic law of those States, regardless of any time-lapses. The competent authorities of the States Parties shall regulate the application of this paragraph by mutual agreement. Social security agreements have been concluded with Australia, Canada, the European Economic Area, India, the United Kingdom, the United States and others. 2.
The competent authority, if the objection appears to it to be justified and if it is unable to find a satisfactory solution itself, shall endeavour to resolve the matter by mutual agreement with the competent authority of the other Contracting State with a view to tax evasion which is not in conformity with this Agreement. . . .